Ethos Ethics A paradigm of professionalism 1 Simply

Ethos & Ethics A paradigm of professionalism 1

Simply well said… No ethic is as ethical as the work ethic. John Kenneth Galbraith Relativity applies to physics, not ethics. Albert Einstein Quality is the best business plan. John Lasseter There is no way to succeed in business without the highest ethical standards. Jordan Belfort 2

Message from our Managing Partner At Nangia & Co LLP we are passionate about people, and the opportunity for each of us to reach our own great potential. Our Code of Conduct is the foundation of our ethics and compliance program. It helps us to articulate our standards of behavior, as we approach our work with professionalism and integrity. Each and every day we seek to make an impact that matters to our people, our communities, and the clients that we serve. Our shared core values of collaboration, responsibility to society, teamwork, agility, innovation, versatile, excellence and ethical integrity underpin everything we do and hence we name our core values as CREATIVE. Mr. Rakesh Nangia Acting in accordance with the Code is a responsibility for all people working with Nangia & co LLP. Each of us is expected to know, understand comply with the Code. We also have a responsibility to raise our voice when we become aware of anything that is inconsistent with it. It’s our expectation that, after reading this Code, you will have a better sense of your vital role, and of the broad support you have from the highest levels of management. In addition, we believe you will also gain a wider understanding of the privileges and responsibilities that come with being a part of this company and the strong framework in which we can all pursue our individual potential. 3

OUR CORE VALUES C R COLLABORATION RESPONSIBILITY TO SOCIETY E A EXCELLENCE T I TEAMWORK AGILITY INNOVATION V E VERSATILE ETHICAL INTEGRITY 4

CODE OF ETHICS Our Code of Conduct is designed to provide an understanding of the standards of ethical conduct that we express to the outside world. The Code applies to all Nangia & Co. Partners and employees regardless of title or position, and serves as a road map to help guide their actions and behaviors. It describes fundamental ethical principles and efforts to uphold those principles. We base our decisions on the ethical framework as individuals and members of the Firm Upholding and complying with laws of the country Respecting Intellectual capital Acting with professionally integrity Synergetic approach o Upholding our clients’ reputations as well as our own Treating people and the environment with respect Acting in a socially responsible manner Working together and thinking about the way we work Considering the ethical dimensions of our actions Fully compliant to FCPA & UKBA & similar legislations in other countries 5

Applicability Code of Ethics Defines the fundamental principles and to comply with them otherwise which constitutes professional misconduct. Nangia & Co Ethical Conduct Policy applies to all its personnel, contractors/ consultants or any third party acting for or on behalf of the Firm. The same applies equally to all its joint operations where Nangia & Co is the operator. To achieve the mentioned objectives, professionals must comply with these principles Integrity Objectivity Professional Competence and Due Care before fortifying contracts Confidentiality Professional Behavior Technical standards Enactments The First Schedule and the Second Schedule of The Institute of Chartered Accountants of India details the disciplinary action and punitive method in the course of Professional Misconduct, headed by decision making bodies. 6

Duty to Speak Policy Nangia & Co relies on everyone who works for or on behalf of the firm to live up to all of its business principles and internal policies by behaving ethically and responsibly. Any failure to work in accordance with our business principles and internal policies represents a risk to the reputation of Nangia & Co. If any breaches occur despite our system of internal controls, reports by personnel and others provide a means for Nangia & Co to initiate proper investigation and to take any necessary action. Every employee, director or partner of Nangia & Co must follow this policy. We require our personnel, and encourage others, to report any situation where they have a reasonable belief that there has been a breach, or potential breach, of our business principles, internal policies and standards/laws/regulations. Our policy also provides other ways of reporting: For example via internal channels such as the Managing Partner of the firm. Any concerns will be investigated and, where appropriate, feedback will be provided. If it is suspected that a report has not been made in good faith, it will be investigated and, where appropriate, disciplinary action will be taken up to and including dismissal. We aim to create the climate and opportunities for our people and third parties to do the right thing’ and to voice genuinely held concerns about behavior or decisions that they perceive to be contrary to Nangia & Co principles or mandatory internal controls. 7

Code of Conduct 8

ETHICAL INTEGRITY (DOING RIGHT EVEN WHEN NO ONE WATCHING) The three areas in which we believe we can make the most impact and deliver our purpose are building trust and integrity in the market, unlocking sustainable growth in dynamic organizations and creating environments where businesses and people flourish. We serve only clients that we’re competent to serve, who value our service, and who meet appropriate standards of legitimacy and integrity. We are willing to walk away from engagements and clients if our independence, integrity, objectivity, or professionalism could be called into question if we continued. We demonstrate our integrity by never engaging in bribery and corrupt practices. This is vital to maintaining the trust of our colleagues, clients, and others we work with. We at Nangia and Co LLP comply with all applicable laws and regulations, upholding the highest professional standards, providing sound advice, and rigorously maintaining our independence. Integrity underlies all the principles in. 9

Implementation of Code of Conduct We at Nangia & Co adopt the following measures to enforce our Code of Conduct effectively Set the tone ‘from top’ by maintaining a sound system of guidelines duly directed and abided by our Top Management. To assist with seeking advice or reporting concerns, the firm has established several “channels of communication. ” These are formal systems designed to ensure that your question or concern is addressed completely and accurately Adopting a risk-based approach, carry out appropriate due diligence assessment prior to entering into a business relationship with third party, and on an ongoing basis with existing counterparties Adopting a risk-based approach, carry out appropriate due diligence assessment of risks under potential and existing business relationships. 10

Implementation of Code of Conduct (contd. ) Adopt and implement measures to prevent bribes when transacting with our contractors and joint venture partners, and to ensure fair and smooth operations through the supply chain with due respect to the ethics prescribed. Provide an independent, confidential reporting line for actual or suspected breaches and other matters of concern to be raised (Speak Up Duty of Report Policy) Special dedicated resources to check anticorruption and provide support to monitor effectiveness and detect and deter non-compliance. We are committed to creating an environment where we treat each other with respect and trust each other to make the right choices. We encourage and embrace the value that different perspectives bring and appreciate everyone’s contribution to shaping a vibrant economy and the firm’s success. Communicate the word and make people aware of the policy guidelines and its practicality 11

COLLABORATION (Working with clients and others) Our firm is built around our clients and our success depends on their success. We rely upon each other to deliver quality service to our clients and for our individual development. We embrace multicultural experience and diversity as strengths of our global organization. As such, we respect one another and strive for an inclusive environment free from discrimination, intimidation and harassment. We have bought together the specialist knowledge and expertise and insight to provide the best ideas and serviced to our client. We don’t wait for the opportunity rather we create one to collaborate with other to share ideas and drive change. We support our people and will withdraw from working for any clients that put our people under undue pressure or threaten them in exercising their professional duties. 9

RESPONSIBILITIES TOWARDS OUR SOCIETY We do not condone illegal or unethical behavior by our suppliers, contractors and alliance partners. We select suppliers through fair procurement processes We recognize our responsibility as an organization in playing an active and positive role in supporting a successful and sustainable society We recognize that our business operations and our provision of services may at times impact the environment and we work to reduce harmful effects they might have We understand the broader impact that our work has on society, our people, and our clients, and we conduct business with those interests in mind We contribute to society and communities by engaging with non-profit organizations, governments, and other businesses to make a positive impact on local, national or global challenges 10

EXCELLENCE (WE NEVER GET COMPLACENT) We recognize that our competitive advantage is achieved through the excellence of our professional advice and the quality of our service delivery We at Nangia & CO LLP willing to do things differently and recognize what’s not working and willing to change in order to achieve our company goals. We strive relentlessly, constantly improve ourselves, our teams, our services and products to become the best. We at Nangia & CO LLP developing a winning mindset that says, “l want to be great at what I do. I want my work and my personal life to be successful. ” We are committed to providing quality services by bringing together the breadth and depth of our resources, experience and insights to help clients address their needs and problems 14

AGILITY (WE THRIVE IN CHANGE) We at Nangia & CO LLP adapt according to the changes in the internal and external environment without losing momentum or vision. Adaptability, flexibility and balance are three qualities essential to long-term business agility and we thrive to achieve all. We promote a culture that cares about and fosters innovation, professional growth, career development, workplace flexibility and work/life balance. We listen to each other, we succeed when we collaborate, engage in dialogue, and respectfully debate issues. Pulling together our ideas and collective knowledge is fundamental to our ability to innovate and ultimately to our success. 15

TEAMWORK (WE TEAM TO DELIVER) We work together to build trust and solve important problems also encourage collaboration, cultivate curiosity and innovation. We provide a safe, flexible and healthy working environment for our people which is free from discrimination or harassment and enables people to bring their whole selves to work. We believe that talent wins games, but teamwork and intelligence win championships and that is what we thrive in our organization. We consult with each other and value the perspectives of those who are different from us, as well as those who challenge our own point of view. We expect and deliver feedback regularly, candidly and constructively, and positively recognize success. Bringing out the best in each other and creating strong and successful working relationships. 16

INNOVATION (CONTINUING SUCCESS OF ANY ORGANISATION) We promote a culture that cares about and fosters innovation, professional growth, career development, workplace flexibility and work/life balance. We provide only services we are professionally capable of delivering. We collaborate to bring the necessary skills and innovation to our work. We deliver on our commitments. Our firm’s unique and innovative culture of shared enterprise means each of us need to be clear about and deliver on the commitments we make to one another. • 17

VERSATILE (IT’S ALL ABOUT BEING FLEXIBLE) We support and encourage our colleagues to volunteer and seek new opportunities / training and projects to develop their skills and experiences. We continually look for new and improved ways of working. We have a six sigma trained team who continuously work on improving the ways work can be completed. We make sure to share ideas on how we will become the GO-TO Firm and growth and create value for our clients. After all, as a shared enterprise, it’s in all our best interests to share ideas and share responsibility in order to share the reward. 18

Special Guidelines for Nangia & Co Personnel Every active personnel working in any capacity is required to familiarize them with this Ethical Conduct Policy and the Standards referred to in this document Operate in accordance with the Anti-Corruption guideline, not giving or receiving bribes in monetary or in kind with contractors or any third parties Follow the requirements of the Hosting of Public Officials Standard when interacting with government and public officials Ensure a pre-employment screening is undertaken to identify if potential new employees are connected to public officials Promptly report any suspected non-compliance with the Ethical Conduct Policy In the event of any real or perceived conflict of interest between the performance of their duties for Nangia & Co and their private interest, the personnel should promptly notify their line manager so that timely corrective steps can be taken to manage that conflict in accordance with the conflict of interest standard. 19

Our Offices DELHI-NCR A-109, Sector-136, Noida (Delhi-NCR) - 201304, India Tel: +91 -120 -2598000, Fax: +91 -120 -2598010, Email: suraj. nangia@nangia. com MUMBAI 11 th Floor, B Wing, Peninsula Business Park, Ganpatrao Kadam Marg, Lower Parel, Mumbai– 400 013, India Ph: +91 -22 -6173 7000 Fax: +91 -22 -6173 7060, Email: suraj. nangia@nangia. com DEHRADUN 3 rd Floor, NCR Plaza, New Cantt. Road, Dehradun– 248 001, India Ph: +91 -135 -274 7081, +91 -135 -274 7082 Fax: +91 -135 -2747080, Email: suraj. nangia@nangia. com SINGAPORE Nangia & Co (Singapore) Pte Ltd. , 24 Raffles Place, #25 -04 A Clifford Centre, Singapore 048621 Email: suraj. nangia@nangia. com 25

We expect everyone who works at Nangia & co. LLP to behave in accordance with the principles contained in the Code of Conduct. If you do not understand the principles contained within the Code, or are not sure how to apply them, you should consult with an appropriately qualified colleague to get your questions answered. THANK YOU New Delhi | Noida | Gurgaon | Mumbai | Dehradun | Singapore